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PicŪ Basic

Money Laundering

INTRODUCTION

The Proceeds of Crime Act 2002 and Money Laundering Regulations 2003 have broadened the definition of money laundering and increased the range of activities covered by the law.Our policy on money laundering can found here:

Introduction

There have recently been significant changes to the legislation concerning money laundering (the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2003), which have broadened the definition of money laundering and increased the range of activities caught by the statutory framework. As a result, the new obligations now impact on areas of our business and require us to establish internal procedures to prevent the use of our services for money laundering.

Scope

Potentially any transaction could be caught by the money laundering provisions if we suspect money laundering and either become involved with it in some way and/or do nothing about it. Whilst the risk of us contravening the legislation is low, it is extremely important that we take measures to reduce any risk to its minimum.

Client Identification

We will ensure that where we form an ongoing business relationship with a client, or undertake a one-off transaction involving payment by or to a client of 15,000 Euro or more or where a series of linked one-off transactions involving total payment by or to the client(s) of 15,000 Euro or it is known or suspected that a one-off transaction (or a series of them) involves money laundering; then we will request satisfactory evidence of the identity of the prospective client, as soon as practicable after the relationship commences . This applies to existing clients, as well as new ones.

In all cases, the identifying evidence may be retained by us for at least five years from the end of the business relationship or transaction(s).

If satisfactory evidence of identity is not obtained at the outset the business relationship or one off transaction(s) cannot proceed any further.

If there is an unjustified delay in the evidence of identity being obtained from the client or where the client is deliberately not providing the evidence a disclosure will have to be made to the relevant authorities.